Date: 8/10/98 1:01 PM
Subject: File No. S7-16-98
Dear Sirs,
I am a shareholder in a small CPA firm that occaisionally handles SEC filings
for SB companies. I applaud the SEC in its efforts to monitor the information
filed by SEC registrants, and its recent attempt to better define the standards
to which CPA's are expected to adhear. However, your proposed rule defining
improper professional conduct remains somewhat unclear. As I read the rule, a
general concept emerges with which I agree. Unfortunately, when litigation is
envolved, general concepts often give way to exact wording, and your use of such
words as "unreasonable", "substantial", and "should have been known" can be
interpreted in numerous ways.
I would hate to see professional risk raised to a level that would preclude many
smaller CPA firms from participating in this market sector. I feel, at least
affordable service.
Respectfully,
John G. Ratliff